Compliance change log
Rule changes that affect pay-per-call, live transfers and lead gen, newest first. Each entry links to the primary source where we have one.
This is general information, not legal advice. Confirm anything you act on with your own TCPA counsel.
- UpcomingFederal (FCC)TCPAOpt-out
FCC replaces 'revoke all' and lets callers set an exclusive opt-out method
Effective Nov 25, 2026, callers may treat an opt-out from one category of informational robocall as applying only to that category, and may designate one of the rule's listed methods as the exclusive way to revoke consent. A telemarketing opt-out still stops all telemarketing robocalls from that caller. This supersedes the 'revoke all' delay to Jan 31, 2027.
What it means for you: Update opt-out language and dialer/SMS suppression logic before Nov 25, 2026 if you want to use an exclusive revocation method.
Read the explainer and checklist →
Sources: Federal Register, Oct 26, 2026
- Federal (FTC)DNCFees
FTC Do Not Call Registry fees rise for FY2027
Annual access is now $85 per area code (up from $82), max $23,425 for all area codes (up from $22,626), $43 for area codes added in the second half-year. The first five area codes remain free.
What it means for you: Budget the higher fee at your next annual renewal; sharing a subscription across clients is not allowed.
Read the explainer and checklist →
Sources: Federal Register, Aug 26, 2026 · FTC: National DNC Registry for telemarketers
- Industry / litigationLitigation
TCPA class actions on a record pace
TCPAWorld counted 1,072 TCPA class actions filed through May 2026, versus 850 in all of 2025. Later reporting shows September 2026 filings fell year over year, the fourth straight monthly decline.
What it means for you: Litigator scrubbing and consent proof remain must-haves for any outbound or transfer operation.
Read the explainer and checklist →
Sources: TCPAWorld, Jul 6, 2026 · TCPAWorld home
- Federal (CMS)MedicareCMS
CMS CY2027 rule changes the TPMO disclaimer for marketing from Oct 1, 2026
CMS's contract year 2027 Medicare Advantage and Part D rule (91 FR 17583, published April 6, 2026) changes the TPMO disclaimer for marketing starting October 1, 2026. The disclaimer must be given before benefits are discussed, and the reference to SHIP was removed.
What it means for you: Update Medicare call scripts, IVR prompts and ad disclaimers for the 2027 AEP. Keep full call recordings as CMS requires.
Read the explainer and checklist →
Sources: Federal Register, Apr 6, 2026 (CMS CY2027 rule) · CMS 2026 OEP marketing guidelines (PDF) · 42 CFR 422.2267, eCFR
- Federal (FCC)TCPAConsent
FCC formally removes the vacated one-to-one language
A Federal Register notice reinstated the prior text of 47 CFR 64.1200(f)(9), closing out the one-to-one rule after the 11th Circuit's mandate issued April 30, 2025.
What it means for you: The consent definition in the CFR is back to its pre-2023 wording.
Read the explainer and checklist →
Sources: Federal Register, Aug 29, 2025
- Federal (court / CMS)MedicareCMSConsent
Court vacates parts of CMS Medicare Advantage marketing rule; TPMO data-consent rule survives
A Texas federal court vacated the CY2025 rule's fixed-fee cap and contract-terms restriction for agents and brokers, but upheld the requirement that TPMOs get prior express written, one-to-one consent before sharing a beneficiary's personal data with another TPMO.
What it means for you: Medicare publishers and call centers still need per-TPMO written consent to pass beneficiary data; live real-time transfers are treated differently under CMS guidance.
Read the explainer and checklist →
Sources: CMS CY2025 final rule fact sheet · Summary of Aug 18, 2025 ruling
- Federal (Supreme Court)TCPALitigation
Supreme Court: courts aren't bound by FCC TCPA interpretations
In McLaughlin Chiropractic v. McKesson, the Court held the Hobbs Act does not bind district courts to an agency's statutory interpretation in enforcement cases. Judges now read the TCPA for themselves.
What it means for you: Long-relied-on FCC interpretations can be challenged case by case, so outcomes may vary more by court.
Read the explainer and checklist →
Sources: Supreme Court opinion No. 23-1226
- Federal (FCC)TCPAOpt-out
FCC consent-revocation rules take effect (except 'revoke all')
Most of the FCC's 2024 revocation rules took effect: consumers may revoke consent by any reasonable means, and callers must honor opt-outs quickly. The 'revoke all' piece was put on hold by waiver.
What it means for you: Dialers and SMS tools need to catch opt-outs in any reasonable form (e.g., 'stop', 'quit', 'unsubscribe').
Read the explainer and checklist →
Sources: Nixon Peabody alert (Oct 7, 2026) · 47 CFR 64.1200, eCFR
- Federal (court)TCPAConsent
Eleventh Circuit vacates the one-to-one consent rule
In Insurance Marketing Coalition v. FCC, the 11th Circuit held the FCC exceeded its TCPA authority and vacated the one-to-one and 'logically and topically related' requirements. The same day, the FCC postponed the rule's effective date.
What it means for you: Multi-seller consent remains allowed if it is clear and unmistakable, but every seller must still be properly disclosed.
Read the explainer and checklist →
Sources: 11th Cir. opinion (No. 24-10277) · FCC postpones effective date (DA 25-90)
- Federal (FCC)TCPAConsent
FCC adopts the 'one-to-one' consent rule
The FCC adopted a rule requiring prior express written consent to be given to one seller at a time, tied to a logically and topically related interaction. It was set to take effect January 27, 2025, and would have ended multi-buyer comparison-site consent as commonly used in lead gen.
What it means for you: Lead forms listing many 'marketing partners' would no longer have counted as consent for each partner.
Read the explainer and checklist →
Sources: FCC one-to-one consent FAQ
- State (Oklahoma, Florida)State lawMini-TCPA
State mini-TCPAs: Oklahoma OTSA takes effect; Florida narrows FTSA in 2023
The Oklahoma Telephone Solicitation Act took effect Nov 1, 2022, requiring prior express written consent for automated sales calls. Florida amended its FTSA again in 2023 (ch. 2023-150), narrowing the autodialer definition and adding a text safe harbor: the consumer must reply STOP and the seller gets 15 days to stop before a suit. Florida also caps solicitation calls at 3 per 24 hours on the same subject, 8 a.m.–8 p.m.
What it means for you: State laws can be stricter than the TCPA; check call-time windows, call-attempt caps and autodialer definitions by state.
Read the explainer and checklist →
Sources: TCPA.com state telemarketing laws